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FILE - In this Wednesday, Feb. 15, 2012, file photo, migratory birds fly over Mad Island, Texas. Energy companies blamed for the deaths of migratory birds may be harder to prosecute under a century-old law that a federal court in September 2015 ruled applies only to intentional killings. (AP Photo/Pat Sullivan, File)

FILE - In this Wednesday, Feb. 15, 2012, file photo, migratory birds fly over Mad Island, Texas. Energy companies blamed for the deaths of migratory birds may be harder to prosecute under a century-old law that a federal court in September 2015 ruled applies only to intentional killings. (AP Photo/Pat Sullivan, File)

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